Further to my point last week regarding administrative oversights leading to costly penalties, I was alerted to this notification over the weekend via a report from the Environmental Protection Agency, Weekly Activity Report for the Week of March 21, 2011 for Region 5.
“On March 22, 2011, Region 5 filed a Consent Agreement and Final Order (“CAFO”) with Cor-Met, Inc. of Brighton, Michigan that simultaneously commenced and concluded an administrative action alleging violations of the Resource Conservation and Recovery Act (“RCRA”). Cor-Met allegedly failed to: (1) label seven 55-gallon containers with the words “Hazardous Waste,” that were observed in an accumulation area during EPA’s inspection; and (2) failed to date the same seven 55-gallon containers with a start accumulation date. The Agency was prepared to file an administrative complaint and seek a civil penalty of $28,895 for these alleged violations.
In accordance with the RCRA penalty policy, and in consideration of Cor-Met’s cooperation and willingness to negotiate a settlement without litigation, Region 5 agreed to settle this matter for $26,005. Cor-Met also certified in the CAFO that they are presently in full compliance with all the statutory and regulatory requirements of RCRA.”
The number one trigger for a regulatory inspection (according to conventional wisdom) is a complaint by an employee or former employee.
To read more about the EPA’s Audit Policy, click here http://www.epa.gov/compliance/resources/policies/incentives/auditing/auditpolicy51100.pdf
If you would like more information about technical assistance with an environmental compliance issue, contact Matthew Schroeder, P.E. (email@example.com) at 248-932-0228.